Bach Seat

Electronic waste (eWaste) is classified as hazardous waste if it has components that are toxic (poisonous), ignitable/combustible, corrosive, or reactive. Most electronic devices contain heavy metals, such as lead. The BBC reports that the typical personal computer has many valuable, dangerous or valuable and dangerous materials.

Among the hazardous wastes included in the typical PC eWaste are according to the BBC are:

1. Lead in cathode ray tube and solder.
2. Arsenic in older cathode ray tubes.
3. Selenium in circuit boards as power supply rectifier.
4. Polybrominated flame retardants in plastic casings, cables and circuit boards.
5. Antimony trioxide as flame retardant.
6. Cadmium in circuit boards and semiconductors.
7. Chromium in steel as corrosion protection.
8. Cobalt in steel for structure and magnetism.
9. Mercury in switches and housing.

eWaste risks

An article at CIO.com says that a firms major source of potential eWaste disposal liability comes from the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), aka the Superfund law. Under Superfund, the U.S. Department of Environmental Protection (EPA) identifies contaminated sites, arranges for cleanup, identifies responsible parties and seeks compensation for the cleanup costs. Many of these sites are landfills where a firm would typically send trash, including obsolete computer equipment.

Once the EPA targets a firm, they can pay the fine or fight the EPA in federal court. The court proceeding could be a costly and time-consuming investigation in to the environmental impact of the firm. Firms can be on the hook all clean-up costs, unless they can prove they never deposited so much as a printer cartridge at that site. The Superfund law states that all contributors to a contaminated site are jointly and severally liable for the entire cost of the cleanup.

Michigan eWaste rules

Enhancing the Superfund threats are state laws and regulations that affect the disposal of eWaste. For example in Michigan, Governor Granholm signed Senate Bill No. 897 into law in Dec. 2008. The law imposes a new annual registration tax of $2,000 to $3,000 on manufacturers of computers and related equipment sold in Michigan to fund a take-back program. Producers must pay for the collection, transportation and recycling.

The program is available for small businesses (10 employees or fewer) purchasing new computers and televisions. The take-back program is good for up to 7 units per day which may recycle covered electronic devices for free. Covered devices include  computers, peripherals, facsimile machines, DVD players, video cassette recorders, and video display devices. Printers will be added in 2011. Program collection must start by April 1, 2010. The Michigan Department of Natural Resources and Environment (DNRQ) is responsible for enforcing these eWaste laws. Larger firms are on their own and there is no current ban on disposal of e-waste. Firms with locations in New York or California faces much tougher requirements.

Many firms take the opposite approach to dumping eWaste into the landfill. Many firms are retaining their out of date IT assets. In 2007, the EPA estimated the number of desktop computers, monitors and notebooks in storage totaled over 110 million units. Despite the declining cost of office spare, storing obsolete equipment is a waste of money. Storing obsolete equipment creates data loss risks and any residual value in the equipment will disappear. There are steps a firm can take to deal with e-waste.

Disposal plan

CIO.com suggests the first step in disposing of eWaste is a well-thought-out technology disposal plan. The plan should start with an attorney or an environmental consultant to get a fuller understanding of the risks and opportunities. CIO.com says the eWaste plan should address:

• A way to track regulatory changes.
• Develop methods for achieving your business goals in an environmentally and legally sound way.
• Determine the point at which your waste volume puts you in a more restrictive class of regulation.
• Evaluate tax liabilities and incentives.
• Preserve the confidentiality of legal and business-critical information.

The environmental consultant should be able to find alternative options for reusing and recycling out of date equipment. They should be able to identify a network of local computer resale shops, nonprofit groups, and government agencies where businesses can donate, upgrade or recycle used computer equipment. The consultant can develop agreements that shift the burden and financial risks to others who are better situated to manage the issue according to the CIO.com article. One way to defer the eWaste risk is to lease computer equipment rather than buying it. This was the manufacturer is responsible for disposal at the end of the term.

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We have developed eWaste programs and PC life-cycle programs for clients. We try to bring home the problems of storing out of use IT assets including:

• Wasted money for floor space to store equipment and the loss of residual value. especially with high-end equipment which could be re-sold on eBay.
• Data protection regulatory and theft risks. After all. who checks on the old servers once they get stashed in the warehouse?
• Environmental regulatory risks. If a firm stashes away enough obsolete systems and your storage area can change the firms EPA status to a hazardous waste generator.

Ralph Bach has been in IT long enough to know better and has blogged from his Bach Seat about IT, careers and anything else that catches his attention since 2005. You can follow him at LinkedIn, Facebook and Twitter. Email the Bach Seat here.